Chairman Puerto Rico Energy Bureau World Plaza Building

July 30, 2021

Mr. Edison Avilés-Deliz Chairman Puerto Rico Energy Bureau World Plaza Building 268 Ave. Muñoz Rivera Nivel Plaza Suite 202 Hato Rey, PR 00918

RE: SESA’s Comments on Proposed Draft Rule for Interconnection and Net Metering

Dear Mr. Avilés-Deliz:

The Puerto Rico Solar Energy Industries Association Corp., d/b/a/ Solar and Energy Storage Association of Puerto Rico (hereinafter, “SESA”) is an association that represents Puerto Rico’s solar and energy storage industries. It advocates for solar and storage technologies as a central solution to the energy needs of Puerto Rico and promotes public policy that benefits the growth of these industries. It brings awareness and understanding of these technologies to both government policymakers and the public and facilitates collectively beneficial collaboration and good business practices within the industry.

SESA appreciates the Honorable Energy Bureau’s initiative to make the

interconnection process in Puerto Rico modern, standardized, and streamlined for all scales of customer-sited solar & storage. Our comments are aimed at achievement of complete utility compliance with the requirements of Law 17-2019 for automatic and rapid time-bound timeframes for customer interconnection of solar and storage of all scales.

I. SESA Summary of Proposed Interconnection Rule Appendix A of these comments is a SESA 7-page summary of the Proposed Draft Rule.

NEPR

Received:

Jul 30, 2021

10:04 PM

II. Sections of Law 17 pertaining to Automatic Interconnection of systems under 25kW, and 90 day timeline for systems 25kW to 5MW

Appendix B of these comments is a summary of key sections of the text of Law 17-2019 relating to timelines and other important requirements for utility processing of customer notifications (for systems up to 25kW) and solicitations (for systems above 25 kW) for interconnection and net metering. III. The Need for Collaborative Rulemaking Due to the historical challenges of chronic incompliance with Puerto Rico laws and rules regarding Net Metering and Interconnection, SESA encourages a very robust stakeholder engagement as these rules continue on their pathway to perfection. We sincerely appreciate the Preliminary Draft Rule publishing and invitation for stakeholder input. We also encourage an iterative process of improvements upon this Proposed Draft Rule, based upon input received in these comments as well as future workshops, webinars, discussion draft sharing and other steps the Honorable Energy Bureau deems helpful in arriving at new rules which are compatible with the letter and spirit of Puerto Rico laws driving the rapid transition from 97% fossil fuel dependence today to 100% renewable energy. IV. Comments on the Preliminary Draft

We greatly appreciate the Honorable Energy Bureau’s publishing of this new Proposed Draft Rule. The Honorable Energy Bureau’s proposed interconnection rules hold much promise for improvement upon the current paradigm.

However, in our view they do not fully or adequately address all of the existing challenges, including ensuring interconnections in areas limited hosting capacity, and the proposed processes for simplified facilities do not align fully with automatic interconnection requirements within Law 17-2019, the 100% Renewable Portfolio Standard Law.

The accountability and processes within the proposed interconnection

regulations will help customers adopt renewable distributed technologies to the extent the utility follows the regulations. Proposed interconnection processes to utilize energy storage technologies should encourage the use of the technology as a pathway to enable more cost effective and timely interconnection.

PREPA has recently stated that roughly 10% of the island’s 1,100 “feeders” could trigger the need for Supplemental Review and many more likely have electrical service infrastructure (customer service transformer and conductors) not designed to accommodate customer adoption of beneficial electrification technologies. We must strive to create more customer friendly and forward looking processes to address current and future grid needs, so that we can truly achieve automatic interconnection without sacrificing safety and reliability. This can be achieved through a more streamlined interconnection experience for Simplified facilities in conjunction with utility processes that account for deferral and avoidance of distribution primary and customer service upgrades utilizing advanced inverter functions. Interconnection infrastructure deferral benefits should be used in conjunction with proactive utility programs to upgrade utility customer service infrastructure within 30 days of interconnection application request if required based on good engineering judgment.

Hosting capacity of the distribution system must not be solely managed through

Supplemental Review and Study Processes for interconnection management of Queue Position; creating awful customer experiences if there is no queue management to allow for continued interconnection of Simplified Process facilities and/or forward looking planning process to address hosting capacity needs of the distribution system and EPS. We recommend 25 percent of available Hosting Capacity be reserved for Simplified Process facilities to allow for continued customer adoption with the sole technical review for Simplified Process facilities being based on customer service infrastructure review.

Fundamentally, we look to shift functions of the utility within the

interconnection process to have a role in hosting capacity planning and potential cost allocation processes to avoid the need for future customers being forced into Supplemental Review, Study Processes, and the associated delays from Queue Management and Distribution Upgrades. Efficient interconnection processes will work until such time that additional review and study processes are required and will continue to be problematic for future customers if interconnection continues to be managed from an individual customer's perspective as opposed to a perspective to enable achievement of 100% RPS law.

SESA appreciated the efforts undertaken by the Energy Bureau in looking to create functional interconnection processes to Puerto Rico. As expressed within our brief comments, we largely agree with the intentions, but believe Simplified Process facility processes must be further streamlined and we must develop proactive hosting capacity planning processes to ensure Queue Management is only needed for the largest of projects undergoing Study Processes.

Lastly, these Proposed Rules present a great opportunity for the Honorable

Energy Bureau to clarify which entity is responsible for the certification of equipment used in customer-sited renewable energy systems. Given that PREB has ultimate

authority over all components of PREPA’s infrastructure and all equipment connected to PREPA’s infrastructure, we encourage PREB to establish their authority over all other possible agencies (including PREPA, LUMA, OGPe. PPPE, and any other government agencies) in setting the enforceable guidelines for equipment certification of all components of solar and storage installations. Cordially, PJ Wilson Presidente, SESA-PR [email protected]

Appendix A

SESA’s Summary of the Proposed Draft Rule

SESA-PR Summary of Informal Draft New Interconnection Rule 7/20/21 Energy Bureau Docket # NEPR-MI-2019-0009

SESA Summary of Proposed Interconnection Rule Generating Facility and Microgrid Interconnection Regulation

Stated Goal: To establish the rules and processes for the interconnection of generating facilities and microgrids to the Electric Power System in Puerto Rico, in accordance with Act 57-2014, Act 114-2007h1 and Act 17-2019. Key Dates ● Comments are due to the Energy Bureau on or before July 30, 2021. ● Within 90 days of the Regulation the EPS Operator shall launch the Cyber Portal to keep track of

interconnection applications. ● On April 1st of each year, the EPS Operator shall submit to the Energy Bureau and publish a

report on their website all the Interconnection Applications reviewed in the past calendar year ○ Update website with application status on a monthly basis

Who? Regulation applies to any Generating Facility or Microgrid seeking to interconnect to the Electric Power System, except those that only operate independently of the Electric Power System (i.e., not in Parallel Operation).

What? There are three types of interconnection application process:

1. Simplified Process 2. Fast Track Process 3. Study Process

Interconnection customers may participate in one of three Net Metering Programs:

1. Basic Metering 2. Aggregate Metering 3. Shared Net Metering


Overview ARTICLE 2: INTERCONNECTION APPLICATION PROCESS + ARTICLE 3. DISTRIBUTION SYSTEM FAST TRACK PROCESS (P. 13, P. 20)

a. Generating Facilities and Microgrids may apply to interconnect to the Distribution System or Transmission System via:

Simplified Process Fast Track Process Study Process

Eligibility Only for small inverter-based systems with nameplate rating of 50kW or less and export capacity of 25kW or less. Must meet Fast Track process eligibility.

Only for customers with a certified system that meets nameplate ratings and must have a: 1.) single Point of Common Coupling; 2.) Point of Common Coupling on a radial distribution circuit, or a spot network serving one customer; 3.) No more than one service drop

Any other interconnection that is (1) is not eligible for Fast Track Process, or (2) did not pass the Fast Track Process.

Screenings Screening includes fast track requirements with a more expedited timeline.

Optional supplemental review: ● Minimum Load Screen ● Type of generation ● Voltage and Power Quality

Screen ● Safety and Reliability Screen

Screening may include a: 1.) feasibility study 2.) system impact study 3.) transmission system 4.) impact study 5.) facilities study.

Submitting Application

Customer shall be notified by EPS Operator within 3 days whether application is complete. Incomplete applications will have 5 days to respond with required info/materials.



Screening Timeline

7 days 15 days 15 days

NOTE: Microgrids with an Export Capacity above five (5) MW must apply to interconnect to the Transmission System and must be approved by the Bureau in a process that includes citizen participation.


ARTICLE 4. STUDY PROCESS (P. 30) Section 4.02 Scoping Meeting: Meeting where parties review the Interconnection Application, existing studies, determine whether the EPS Operator should perform feasibility study, or proceed directly to a system impact study or studies. A scoping meeting shall be held within 5 Days of a complete application. Type of Screenings: Section 4.03 Feasibility Study.

a. Only conducted if requested by Interconnection Customer b. EPS Operator cannot require a feasibility study. c. EPS Operator has 10 days to complete study from a complete application. d. Customer is responsible for cost of the feasibility study. e. Consists of a power flow and short circuit analysis. f. Also see ATTACHMENT 5 - Feasibility Study Agreement (includes scope of and cost

responsibilities for the feasibility study are described in the attached feasibility study agreement)

Section 4.04. System Impact Study.

a. Identifies EPS reliability and any impacts that would result if the proposed Generating Facility or Microgrid interconnected without project modifications or EPS modifications, and study potential impacts, including but not limited to those identified in the scoping meeting.

i. e.g. ID Equipment, short circuit capability, thermal overload, voltage limits, technical thresholds, construction schedule, cost estimates,

b. Must be completed within 25 days of signed study agreement c. Also see ATTACHMENT 6 - System Impact Study agreement

Section 4.05. Facilities Study

a. The facilities study shall specify and estimate the cost of the equipment, permitting, engineering, procurement and construction work (including overheads) needed to implement the conclusions of the system impact study(s).

b. Design for any required Interconnection Facilities and/or Upgrades shall be performed under the facilities study agreement.

ARTICLE 5. PROVISIONS THAT APPLY TO ALL INTERCONNECTION APPLICATIONS (P. 36)

Section 5.01. Interconnection Agreement

a. 5 days for EPS Operator to provide agreement to customer b. 30 days for customer to sign and return agreement c. 2 days to provide executed agreement after receiving signed agreement from customer


Section 5.02. Energy Bureau’s Approval for Microgrids Above 5 MW

a. For Microgrids with an Export Capacity above 5 MW, after the Facilities Study has been completed, customer or the EPS Operator submits System Impact Study and Facility Study to the Energy Bureau for approval. If approved by the Energy Bureau, the EPS Operator shall issue the corresponding Interconnection Agreement.

Section 5.03. Time Frames and Extensions

a. The Energy Bureau may fine the EPS Operator $1,000 per day if it fails to comply with the time frames and other requirements of this Regulation. The Energy Bureau also maintains the authority to impose other applicable fines or administrative penalties to enforce its orders and regulations.

Section 5.04. Interconnection Metering and Telemetry

Interconnection of with generation capacity over 1 MW requires customer to install and maintain 2 power meters at the Point of Common Coupling for exclusive use of the EPS Operator; one located at the exit to measure production and power factor; and the second meter for metering instantaneous power of the Energy Storage system.

Section 5.12. Export Capacity of a Generating Facility or Microgrid

1. Non-Exporting systems a. Reverse Power Protection b. Minimum Power Protection c. Relative Generating Facility Rating:

2. Limited Export systems only. a. Directional Power Protection b. Configured Power Rating

ARTICLE 6. TECHNICAL REQUIREMENTS (P. 46)

All equipment based on renewable energy sources must be approved by the Public Energy Policy Program (“PEPP”), of the Department of Economic Development and Commerce (“DEDC”) including, but not limited to, photovoltaic modules, wind turbines, synchronous generators, induction generators, inverters and control systems.

Must interconnect through an Interconnection Transformer. No direct interconnection to the Distribution System is allowed.

Section 6.04. Intentional Islanding for Microgrids Microgrid can disconnect

due to:

1. voltage disturbances 2. frequency disturbances


3. planned Island request issued by EPS Operator 4. When Paralleling a Microgrid to the EPS 5. Alternative to Unintentional Island detection

Section 6.08. Power Factor

The Generating Facility or Microgrid must be set to maintain a continuous unity power factor (PF = 1.0) at the Point of Common Coupling

Section 6.09. Power Quality

● Interconnection should not cause degradation (i.e. flicker, low voltage, interruptions, etc.) in the quality of the signal of the EPS.

● Any impacts will result in disconnection from the EPS until the Interconnection Customer makes the modifications to mitigate the problems.

ARTICLE 7. NET ENERGY METERING (P. 55)

Section 7.01. Participation in Net Metering Programs a. Energy Storage Paired with Net Metering System

i. While an Energy Storage device may be paired with a Net Metering System, an Energy Storage device standing alone does not qualify as a Net Metering System.

ii. When an Energy Storage Device is paired with a Net Metering System, the Generating Facility shall be programmed with one or both of the following operating restrictions:

(i) Restricted from exporting electricity to the Electric Power System (ii) Restricted to being charged solely from the customer’s Net Metering System and

not from the Electric Power System.

Basic Net Metering

Aggregate Net Metering Shared Net Metering

Customer Type

Only governmental entities and non-profit academic institutions.

Exclusively for residential and commercial customers with primary and secondary voltage distribution services under a horizontal property regime (i.e. residential, commercial or mixed-use condominiums). Also applies to public housing managed by the Department of Housing.

Load Requirements

Max installed AC capacity of 25 kW for residential customers and 1 MW for commercial, industrial, etc. Generating Facilities connected to subtransmission/transmission systems shall

Customers with service on distribution voltages, the max installed AC capacity of the Generating Facility must be 1 MW. For customers with service on transmission or subtransmission voltages, the maximum installed AC capacity of the Generating Facility must be 5 MW.

For residential cases, the max capacity of the Generation Facility is 25 kW per customer or the capacity of the Interconnection Transformer up to a maximum of 1 MW. For commercial or mixed use cases, the max capacity of the Generating Facility is the same as the capacity of the


have a max installed AC capacity of 5 MW for commercial customers.

Interconnection Transformer, up to a maximum of 1 MW.

Service Agreements

The service agreements to which the energy is to be accredited must be (1) within the same location where the Generating Facility is installed or (2) in other locations interconnected to the same power line at a distance not greater than two miles from the Generating Facility.

Location of the service agreements for energy accredited must be within the same location of Generating Facility . All service agreements must be serviced from the same point of delivery to which the Generating Facility is interconnected.

Compensation

(1) Service agreements at the same location: max amount of energy to be credited to all may be up to 100% of consumption. (2) Service agreements at different locations: Max amount of energy to be credited to all participating service agreements may be up to 120% of consumption (100% at location and 20% credited equally among other locations in the same account).

100% of the energy produced by the Generating Facility will be credited equally among all participants of this program.

Energy Compensation for Customers that Participate in the Net Metering Programs

Energy exported by the customer shall be compensated as described below: a. For each billing period, the EPS Operator will measure the energy that the customer consumes from

and the energy that the customer exports to the EPS. b. If during a billing period, the EPS Operator supplies the customer more energy that the customer exports,

the customer will be charged for their Net Consumption. c. For customers connected to the Transmission System, any excess in exported energy during a billing period

will be registered up to a daily maximum of 50 MWh. d. Excess in exported energy will be carried over to the invoice for the next billing period.

i. Any excess in exported energy accumulated during the year and hasn’t been used by end of June billing period of each year:

● ten cents per kilowatt-hour or ● price per kilowatt-hour that results from converting the average of the total price charged to

customers throughout the year and subtracting the average of the fuel and power purchase adjustments.

● customer will receive a credit on their monthly bill equal to 75% of the surplus energy and the remaining 25% of the surplus energy will be credited to the power bill of the Department of Education.


ARTICLE 10. PUBLIC REPORTING AND RECORD RETENTION (P. 61)

Section 10.01. Public Queue

The EPS Operator shall maintain a public interconnection on its website in a tabular format, i.e., a sortable spreadsheet, which it shall update on at least a monthly basis. The date of the most recent update shall be clearly indicated. The public queue should include:

a. Queue Position, i.e., queue number b. Nameplate Rating c. Export Capacity d. Primary fuel type (e.g., solar, wind,

bio-gas, etc.) and secondary fuel type e. Exporting or Non-Exporting f. City/Zip code g. Substation, feeder h. Status (active, interconnected,

withdrawn, etc.)

i. Dates (application, notification) j. Fast Track results k. Supplemental review results l. Feasibility Study results m. Transmission system impact study

results n. Facilities study results o. Estimated and Final Cost

Section 10.02. Annual Interconnection Report

By April 1 of each year, the EPS Operator shall submit to the Energy Bureau and publish on its website a report on Interconnection Applications reviewed in the past calendar year, including:

1. #, Nameplate Rating, and Export Capacity of, completed Interconnection Applications for Generating Facilities and Microgrids received, approved, studied, installed, withdrawn, and denied under the Simplified Process, the Fast Track Process, and the Study Process.

2. The fuel type, number, Nameplate Rating, and Export Capacity of Generation Facilities and Microgrids approved for interconnection.

3. The fuel type, number, Nameplate Rating, and Export Capacity of all Generation Facilities and Microgrids currently interconnected to the EPS.

4. A narrative description of data, including any trends identified by the EPS Operator 5. Data in tabular format, i.e., a searchable spreadsheet.

Appendix B

SectionsofLaw17-2019onAutomaticInterconnection&30-DayNetMeteringforsystemsupto25kWinsize,and90-dayMaximumApprovalTimeforsystemslarger

than25kW

Law 17-2019: Section on Automatic Interconnection & 30-Day Net Metering for

systems up to 25kW in size, and 90-day Maximum Approval Time for systems larger

than 25kW

Section 3.9.- Section 9 of Act No. 114-2007, as amended, is hereby amended to read as follows:

“Section 9- Public Policy on Interconnection.

It shall be the public policy of the Government of Puerto Rico to ensure that the procedures for the interconnection of distributed generators to the electric power system are effective in terms of costs and processing time, in order to promote the development of these types of projects and incentivize economic activity through the reduction of energy costs in the residential, commercial, and industrial sectors. For such reason, it is hereby established that the procedures for the interconnection of distributed generators with a generating capacity of up to five (5) megawatts (MW) which shall participate in the Net Metering Program, shall use as a model the Small Generator Interconnection Procedures (SGIP) and the Small Generator Interconnection Agreement (SGIA), provided in Order No. 2006 of the Federal Energy Regulatory Commission (FERC), as amended, and any other future amendments thereto that are adopted by the Energy Bureau. The interconnection procedures shall be uniform in all regions.

Using the provisions of the SGIP as a model, the Electric Power Authority or the transmission and distribution network Contractor shall approve expedited processes so that distributed generators with a generating capacity of less than one megawatt (1MW) may connect to the grid, provided, that the technical features of the distributed generator to be interconnected and the existing conditions of the electric power grid thus allow. Provided, that for the interconnection of generators

with a generating capacity of more than five hundred kilowatts (500KW) but less than one megawatt (1MW), the Bureau may require the necessary reliability studies. An engineer or

an expert electrician, both members of their professional associations and admitted to the practice of their profession, shall certify that the electrical installation of the distributed generation system meets the specifications required by the interconnection regulations, and that the same was completed in accordance with the laws, regulations, and rules applicable to the interconnection of distributed generation to the transmission and distribution system. Once said certification is submitted to the Authority, its successor, or the transmission and distribution network Contractor, the proponent shall interconnect and operate his distributed generation system with the electrical system provided that the generation capacity of said system does not exceed 25 kilowatts. The Authority, its successor, or the transmission and distribution network

Contractor shall evaluate the application for interconnection as established in the interconnection regulations. Such evaluation, however, shall not exceed ninety (90) days from the filing thereof as established in the regulations approved by the Energy Bureau. In the event of noncompliance with the term provided, the application for interconnection shall be automatically approved until the Authority, its successor, or the transmission and distribution network Contractor, as appropriate, provides the grounds for denying the interconnection or deems necessary to implement additional technical requirements and/or improvements to the electric power distribution system. In these cases, the applicant shall be entitled to challenge such a determination or findings through any of the processes provided through regulations on review resources or procedures relating to the interconnection of a distributed generator approved by the Energy Bureau.

Nothing prevents the subsequent review of the correction of the certification issued by an electrical engineer or an expert electrician, both members of their professional associations and admitted to the practice of their profession.

However, in the case of interconnected photovoltaic or renewable energy generation systems whose generation capacity does not exceed 25 kilowatts, the following shall apply:

(a) Photovoltaic or renewable energy generation systems registered in the renewables registry of Act No. 82-2010, whose generation capacity does not exceed 25 kilowatts shall be interconnected automatically to the transmission and distribution network. The systems shall begin operating automatically once an electrical engineer or an expert electrician, both members of their professional associations and admitted to the practice of their profession and who are certified photovoltaic or renewable energy system installers, certifies the compliance thereof with the regulatory technical requirements for interconnection to the distribution network. It shall not be necessary to submit an application for interconnection in order for the systems identified herein to be deemed interconnected and to activate net metering.

(b) The net metering for these generation systems shall be reflected in the customer’s monthly bill not later than thirty (30) days after the receipt of notice of the certification of the distributed generator installed by an engineer or an expert electrician, both members of their professional associations and admitted to the practice of their profession.

(c) The fact that the feeder exceeds its capacity shall not constitute an obstacle for the interconnection of photovoltaic or renewable energy systems with a generation capacity that does not exceed 25 kilowatts. In such cases, the necessary improvements and/or changes to be made to the feeder shall be defrayed by the requesting company.

(d) None of the provisions of this Section prevent the subsequent review of the correction of the certification of the distributed generator.

However, photovoltaic generation systems established in accordance with the parameters of EO-2017-064, ‘to provide electric power to homes through photovoltaic generation systems and batteries, and accelerate the recovery of the Puerto Rico electric power system after Hurricane Maria,’ shall be deemed to be automatically approved to operate and participate in the Net Metering Program, provided that the provisions of EO-2017-064 are complied with during the effectiveness thereof. However, residential photovoltaic energy storage systems built pursuant to the aforementioned Executive Order do not have to meet

the remote operation and battery status monitoring requirements to be deemed automatically approved to operate and participate in the Net Metering Program.

Residential customers that hold an Interconnection Agreement prior to February 2017 shall not have to renew it, and such agreement shall remain in effect provided that the electric power service contract for the property where the distributed generation system is located remains in effect.”

Section 3.10.- Section 10 of Act No. 114-2007, as amended, is hereby amended to read as follows:

“Section 10.- Rulemaking Authority.

The Electric Power Authority is hereby directed to adopt or modify regulations as needed for the faithful compliance with this Act in accordance with the standards and technical requirements established by the Energy Bureau. Said regulations shall be promulgated within a term not to exceed one hundred eighty (180) days after the approval of this Act.

The Electric Power Authority shall be required to promulgate regulations for the interconnection of distributed generators with a generating capacity of less than one megawatt (1MW), as well as regulations for the interconnection of distributed generators with a generating capacity between one megawatt (1MW) and five megawatts (5MW) to be connected to sub-transmission facilities. Such regulations shall be consistent with the public policy on interconnection set forth in Section 9 of this Act and shall ensure the reliability and safety of the electric power system. Said regulations for the interconnection of distributed generators shall be promulgated within a non-extendable term of one hundred eighty (180) days after the effective date of this Act. Furthermore, PREPA shall amend any other regulations in effect that govern or are related to the Net Metering Program to conform it to the provisions of this Act and the terms and procedures to be included in the regulations for the interconnection of distributed generators.

In the event that the Electric Power Authority fails to promulgate or modify the regulations for the interconnection of distributed generators on or before one hundred eighty (180) days after the approval of this Act, the evaluation and approval process of applications for interconnection of distributed generators shall be established by the Energy Bureau, following the best practices of the industry. Such process shall have the purpose of reducing administrative steps while safeguarding the reliability and safety of Puerto Rico’s electric power grid, and ensuring compliance with the public policy on energy of the Government of Puerto Rico.

Any amendment proposed by the Authority, its successor, or the transmission and distribution network Contractor to the regulations for the interconnection of distributed generators must be submitted to the Energy Bureau in order to hold public hearings as established in this Act. Any amendment proposed by the Bureau to the regulations for the interconnection of distributed generators shall follow the process established in this Section.

The Bureau shall be required to hold public hearings prior to the approval of any amendment to the regulations for the interconnection of distributed generators. Such public hearings shall not be held within less than thirty (30) days after the publication of the public notice of the proposed amendment to the regulations for the interconnection of distributed generators. Thirty (30) days after the public hearing process has concluded, the Bureau shall issue its determination about whether or not the amendment to the regulations for interconnection shall be accepted. Once the decision of the Bureau becomes final and binding, the Bureau shall amend the regulations for the interconnection of distributed generators in accordance with those amendments adopted pursuant to such decision.”

.

Documents

Chairman Puerto Rico Energy Bureau World Plaza Building